James R. Brown

Willkie Farr & Gallagher LLP

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Recently by James R. Brown

Finance

Tax Changes For Investment Funds And Their Investors In Fiscal Cliff Legislation

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act addresses, among other things, provisions of the Internal Revenue Code that were scheduled to expire on December 31, 2012, or had expired previously, including many of...

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Regulatory & Compliance

Preparing For The Possible Enactment Of Carried Interest Legislation

With the election settled, many clients are again asking about the President’s controversial proposal to change the taxation of “carried interest” and what, if anything, they can do to mitigate its potential effects. We cannot predict whether or when this proposal might be...

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Finance

The IRS Proposes New Rules Under Section 892 That May Simplify Foreign Governments’ Investments In The United States, Including In Private Equity Funds

On November 2, 2011, the Internal Revenue Service (the “IRS”) issued proposed regulations under section 892[1] (the “Proposed Regulations”) that provide guidance to foreign governments and their controlled entities for making investments in the U.S. The Proposed...

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Regulated Investment Company Modernization Act Of 2010 Passed

On December 22, 2010, President Obama signed into law the Regulated Investment Company Modernization Act of 2010 (the "Act"). The Act updates certain tax rules applicable to regulated investment companies ("RICs"), including open-end mutual funds and closed-end funds. Unless...

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